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JARAVATA V.

SANDIGANBAYAN
127 SCRA 363
G.R. No. L-56170. January 31, 1984

FACTS:
This is a petition to review the decision of the Sandiganbayan in Criminal Case No. 873.
Hilario Jaravata an Assistant Principal was charged before the Sandiganbayan where he found guilty
beyond reasonable doubt for Violation of Section 3(b), Republic Act No. 3019
It was averred that Jaravata using his influence as a public official and taking advantage of his
moral and official ascendancy over his classroom teachers made demand and actually received
payments from other classroom teachers, ROMEO DACAYANAN, DOMINGO LOPEZ, MARCELA
BAUTISTA, and FRANCISCO DULAY various sums of money total of 338 pesos in consideration of accused
having officially intervened in the release of their salary differentials.

The Sandiganbayan states in its decision the following:


A perusal of the conflicting versions of the prosecution and the defense shows that there is no dispute
that complainants Ramos, Lloren, Lopez, Dacayanan, Dulay and Bautista are classroom teachers of the
Leones Barangay High School with accused as their assistant principal and [Conrado Baltazar as the
administrator; that on January 5, 1979, accused informed the classroom teachers of the approval of the
release of their salary differentials for 1978 and to facilitate its payment accused and the classroom
teachers agreed that accused follow-up the papers in Manila with the obligation on the part of the
classroom teachers to reimburse the accused of his expenses; that accused incurred expenses in the
total amount of P220.00 and there being six classroom teachers, he divided said amount by six or at the
rate of P36.00 each; that the classroom teachers actually received their salary differentials and pursuant
to said agreement, they, with the exception of Lloren and Ramos, gave the accused varying amounts but
as Baltazar did not approve it, he ordered the accused to return the money given to him by Lopez,
Dacayanan, Dulay and Bautista, and accused complied (Pp. 7-8.) The decision also recites that "the
evidence is overwhelming to show that accused received more than the rightful contribution of P36.00
from four classroom teachers, namely: Lopez, Dulay, Dacayanan and Bautista. Lopez categorically
declared that he gave the accused P100.00 (TSN, p. 5, August 21, 1980 hearing) after he received his
salary differential or an excess of P64.00. So with Dulay, that he gave P70.00 to the accused (TSN, p. 16,
supra) or an excess of P34.00; Dacayanan, that he gave to the accused P118.00 (TSN, p. 26, supra) or an
excess of P82.00, and Bautista, that he gave to the accused P50.00 (TSN, p. 38, supra) or an excess of
P14.00. In short, the total amount received by the accused in excess of the share of the classroom
teachers in the reimbursement of his expenses is P194.00. " (P. 9.)

ISSUE: Whether or not, under the facts stated petitioner Jaravata violated the provision
Section 3(b) of Republic Act No. 3019?

RULING: No, the court held in negative. The court said that there is no law which invests the petitioner
with the power to intervene in the payment of the salary differentials of the complainants or anyone for
that matter. Far from exercising any power, the petitioner played the humble role of a supplicant whose
mission was to expedite payment of the salary differentials. In his official capacity as assistant principal,
he is not required by law to intervene in the payment of the salary differentials. Accordingly, he cannot
be said to have violated the law afore-cited although he exerted efforts to facilitate the payment of the
salary differentials.

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